Oakville Centre for Cognitive Therapy Privacy Policy 

At the Oakville Centre for Cognitive Therapy, privacy of personal information is important to us. We use appropriate protections when collecting, using, and disclosing personal information. This privacy policy describes in more detail the measures we take in protecting the privacy of our clients, to assist you in understanding how we handle this information. 

Who Are We? 

The Oakville Centre for Cognitive Therapy is a large group practice consisting of psychologists and administrative staff, as well as psychologists in supervised practice and Ph.D. level psychology students in their senior years working under a psychologist’s supervision. We also use the services of consultants or agencies that, from time-to-time, may have limited access to personal information we have collected (e.g., office security and maintenance staff, IT services and consultants, accountants/bookkeepers, lawyers, credit card companies, temporary staff to cover holidays). Their access to any personal information is restricted as much as reasonably possible, and we have their assurance they are following appropriate privacy guidelines.   

What is Personal Information? 

We collect both personal information and personal health information throughout the provision of services. Personal information as defined by the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada, is considered any information about an identifiable individual, which includes (but is not limited to), the individual’s name, date of birth, gender, address, phone number, email address, contact information, and any additional information about the individual that is disclosed to us. Personal information is considered different than business information (such as the contact information for a business), which is not protected under privacy legislation.

Personal health information as defined by the Personal Health Information Protection Act (PHIPA) of Ontario, includes (but is not limited to) any information that relates to an individual’s physical or mental health, medical records, prescriptions, health number, and health history.

At the Oakville Centre for Cognitive Therapy, we take the precautions described below to protect your personal information and personal health information. In this document, we use the term personal information to refer to both personal information and personal health information. 

Purposes for Collecting Personal Information 

Main Purposes

The main purpose for which the Oakville Centre for Cognitive Therapy collects, uses, and discloses personal information, is in the provision of psychological services, including assessment and treatment. For example, when working with an individual, we collect information about that individual’s psychological and physical condition, health history, family history, and social situation. This information helps us to assess what the client’s mental health needs are, to advise the client of their options, and to provide the services that the client chooses.

Another main purpose for the collection of personal information is to monitor treatment progress and changes over time, by collecting information on psychological functioning at the beginning of treatment and at various points in treatment.

We also collect personal information when conducting comprehensive assessments with the goal of providing a professional opinion of psychological functioning and recommendations. In these instances, with the client’s consent, the professional opinion can be disclosed to a specified agency or individual. With your consent, we may share this information with another treatment provider involved in your care (e.g., physician, therapist) or with a specified agency or individual not involved in your treatment (e.g., providing a professional opinion to the Workplace Safety and Insurance Board, an insurance board, Children’s Aid Society, rehabilitation companies, a school board or other educational facility, a lawyer, or for psychological/legal reports).

Additional Purposes

Similar to most organizations, we also collect, use, and disclose personal information for reasons that are secondary to the provision of psychological services. These additional purposes include:

• For payment (e.g., invoicing for services that were not paid for at the time the services were provided, processing credit card payment information, collecting unpaid accounts).
• To inform clients and other individuals of any opportunities or special events that may be offered at our clinic (e.g., a workshop, seminar, new service).
• Disclosure of information to third-party payers with your consent (e.g., insurance companies, Workplace Safety and Insurance Board). Note that these third-party payers often have your consent or the legislative authority to request that we disclose to them specified information to demonstrate entitlement to funding.
• We may also report serious misconduct, incapacity, or incompetence of other practitioners, including those at the Oakville Centre for Cognitive therapy, or practitioners outside of our clinic.
• From time-to-time insurance companies conduct audits to ensure that services have occurred. These insurance companies often have your consent for us to disclose this information to them, and in these instances we may provide the insurance company with the information they require to process your claim. This information may include general details such as the date the service was provided, the duration of the appointment, the amount of the session, and confirmation payment was received. Only non-health-related information will be provided to process your claim.
• The College of Psychologists of Ontario may review our records and/or interview psychologists and psychologists in supervised practice if they are involved in the College’s regulatory activities. Note that the College of Psychologists of Ontario adheres to strict privacy obligations.
• As with all organizations, certain government agencies (such as the Human Rights Commission, Canada Customs and Revenue Agency, Information and Privacy Commissioner) have the authority to access our files and interview staff. In such circumstances we may consult with relevant professionals to help investigate the matter (e.g., lawyers, accountants).
• If a psychologist in supervised practice or a Ph.D. level psychology student is being supervised by a more senior psychologist, they will discuss clinical information for supervisory purposes, and the supervisor may access the client’s clinical file. Clients are always informed of such arrangements ahead of time.
• It is possible that if the Oakville Centre for Cognitive Therapy were to be sold, the purchaser(s) may request to complete a due diligence review, which could include a review of the clinic’s records to ensure the business has been portrayed honestly and that it is a viable business. The review may include service files and accounting files. In this instance, the purchaser(s) would be required to provide a written promise to ensure all personal information is kept confidential. Only reputable purchasers and those who have agreed to purchase the clinic and its assets would be given access to this information, and it would be for the sole purpose of completing the due diligence search. Additionally, the purchaser(s) could not record or remove personal information.
• The clinic Co-Directors and administrative team may review client files to ensure high quality services are being provided, such as for assessing the performance of Associates and staff. We may also hire external consultants (e.g., practice consultants, accreditation programs, lawyers, auditors) to conduct audits or reviews for quality improvement, which may require such consultants to review client files and interview staff members of the clinic.

It is possible that in rare emergency situations, we may need to collect personal information without the client’s expressed consent.

Information Provided to Us from Others

If there is a situation in which it would be impractical to obtain consent and we believe the client would consent if asked, such as if a family member was passing along information from a client and we do not have any reason to believe this message is not genuine, we may also collect this information without the client’s expressed consent. Although we cannot control what personal information is sent to us from our clients or from third parties (e.g., client family members, lawyers, other health care providers, insurance companies), the Oakville Centre for Cognitive Therapy takes reasonable steps to maintain the security and confidentiality of this information and will make our best efforts to respond in a manner that protects the privacy of the client.

Members of the General Public

When members of the general public contact us to inquire about services, we may collect personal information (e.g., contact information, date of birth, presenting concerns) in the process of informing these individuals about the range of services, and guiding them to appropriate services.

Protection of your Personal Health Information

At the Oakville Centre for Cognitive Therapy, we understand that it is important to protect the security of our clients’ personal information. We take reasonable steps consistent with the Personal Health Information Protection Act (PHIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA), to protect the security and confidentiality of the information that is sent, stored, used, and received. Specifically, we take the following steps to protect your personal information:

• Paper with personal health information is stored in a locked or restricted area or is under supervision.
• Any video-conferencing platform used at our clinic for virtual/remote sessions are designed to maintain your confidentiality and meet PHIPA security standards (e.g., encrypted data transmission).
• Computers and mobile devices are either stored in a locked or restricted area or are under supervision and are protected by the use of a password.
• Computers are encrypted, and are equipped with firewalls, malware scanners, and antivirus programs.
• Paper with personal health information is sent via sealed, addressed envelopes and we use reputable companies to transmit this information.
• Emails with sensitive personal health information are either anonymized or sent through encrypted attachments.
• Any files being transported or stored outside of the clinic are required to be stored in a locked area.
• If an Associate leaves Oakville Centre for Cognitive Therapy, your electronic client file will remain at our clinic but a copy of the file may also be transferred securely to the Associate (as they are the health information custodian of your records). Paper files may remain at Oakville Centre for Cognitive Therapy but will likely be stored by the Associate who is leaving. In some circumstances the Associate and Clinic may choose to make a copy of the paper file to be stored by both parties. Requests for information in the future can be made to Oakville Centre for Cognitive Therapy, at which time we will contact the Associate so they can review the file and address any questions/requests (if applicable).
• All associates as well as administrative staff are trained to follow the privacy policies outlined herein.
• External consultants that will have access to personal health information through the course of their work for us (e.g., accountants, IT consultants) have agreed to maintain the privacy of client information.

Limits to Protection of Personal Information

The information shared between you and your psychologist will be kept strictly confidential and such information will only be disclosed to another person(s) with your consent. However, the following situations are exceptions whereby your psychologist may be ethically and/or legally obligated/permitted to break confidentiality:

• If we have reason to believe a client (or anyone else a client tells us about) is at risk of harming a potential victim we can inform the police, the victim(s), and any other individual, as appropriate.
• If we have reason to believe a client is at risk of seriously harming him/herself and/or ending their own life we would inform the police, certain health care providers, and/or appropriate family members/friends.
• If a client divulges information related to past/potential childhood abuse, including: physical, sexual, emotional abuse or neglect, and we have a strong enough suspicion that a child is at risk of/in need of protection, we would be required to contact the Children’s Aid Society (and possibly the police) to report our concerns.
• If a client indicates that a regulated health professional has sexually assaulted or made inappropriate sexual remarks to their client, we would be required to inform that health care provider’s regulatory body (College) to ensure they are appropriately disciplined. A client’s name would not be divulged during this reporting unless we had written consent from the client to provide it.
• If a client provides information that a person in a long-term care facility or retirement home is being abused or neglected, we would be required to inform the appropriate authorities to ensure their protection.
• If there is a court order requiring the release of a client’s clinical record we would be required to provide this information.
• If there is a request by a police officer to assist in locating a missing person, the release of client clinical records would be required in response to an urgent demand, an order for the production of records, or a search warrant.
• If there is a need to be in contact with The College of Psychologists of Ontario to fulfill the requirements of an audit of our services, to comply with supervision responsibilities, or for us to receive consultation about psychological practices, we would have to release personal health information to the College in order to do so.
• A client’s information may be shared between the Co-Directors and the administrative team at the Oakville Centre for Cognitive Therapy for quality assurance purposes.
• A client’s information may also be shared between the Associates for consultation or training purposes. Associates as a rule will not provide any identifying client information during these discussions. In rare instances when this is not reasonably possible, some identifying information may be shared, although you can withdraw your consent around providing identifying information by informing your psychologist/clinician.
• A client’s information may be shared with appropriate members of their health care team (e.g., family doctor, psychiatrists) for consultation purposes. For this particular limit you may withdraw your consent by informing your psychologist/clinician.

Note that if we are obligated / permitted to break confidentiality for one of the reasons mentioned above, we will not release more information than what is required or allowed.

Retention and Destruction of Personal Information

To ensure we can answer any questions you may have about services provided, and for accountability to regulatory bodies, we retain personal information for an extended period of time. For example, many of our clients receive ongoing services for months or years and previous records are helpful for this continued service. We only retain this information for as long as necessary for the purposes it was collected, in accordance with the laws, ethics, and standards applicable to members of the College of Psychologists of Ontario. As such, our client files are kept for a minimum of 10 years after the last point of contact with the client. Note that for individuals seen before the age of 18, the College requires us to retain their records for a minimum of 10 years after they turn 18.

We may destroy or anonymize your personal information in accordance with the applicable laws when it is no longer required to be maintained. Specifically, paper files with personal information are destroyed by shredding. Electronic files are deleted, and/or the hard drive is physically destroyed before the hardware is discarded. We destroy or anonymize any personal information that is not part of the permanent clinical file if reasonably possible to do so.

You Can Access Your Personal Information

You have the right to see the personal information that is collected about you, with a few exceptions. To see this information, often all that is required is asking for the information. We do reserve the right to charge a nominal fee for any requests for access to personal information, which will depend on the required time to make this information accessible. We may request confirmation of your identity prior to providing access to this information, and we may ask that you put the request in writing. If requested, we will help you in identifying what records we have with your information, and will also try to help you in understanding any information you do not understand in the record. In the event that we are not able to provide you with access to this information, we will inform you of this and tell you the reason we cannot give you access as best as possible, within 30 days.

If you believe there has been a mistake in your client record, you have the right to request that this mistake be corrected. We might ask you for documentation regarding the mistake, and if agreed that a mistake has been made, we will make the applicable correction and inform anyone who has been sent this information. In the case that we do not agree a mistake has been made, we will add to the file a statement from you regarding the mistake and this statement will be forwarded to anyone who has been sent this information. Note that requests for corrections can be made regarding factual information only, and not regarding professional opinions that we have formed.

Questions?

Any questions about this Privacy Policy or handling of your personal information can be directed to our Privacy Officer:

Dr. Justin Mattina, Ph.D., C.Psych.

1235 Trafalgar Rd, Suite 405

Oakville, ON, L6H 3P1
Contact No: (905) 338-1397

Email: admin@oakvillecbt.ca

If you would like to make a formal complaint about the privacy practice at the Oakville Centre for Cognitive Therapy, you can make it in writing or by email to our Privacy Officer at the address/email listed above. He will ensure the complaint is investigated and you are given a formal written decision regarding the complaint.

If you have any concerns about the mental or physical capacity of our staff, or the competence or professionalism of services provided at the Oakville Centre for Cognitive Therapy, we ask that you discuss these concerns with us. If we are not able to satisfy these concerns, you are also entitled to file a complaint with our regulatory body, which can be done at the following address:

College of Psychologists of Ontario
110 Eglinton Avenue West, Suite 500
Toronto, Ontario
M4R 1A3

We will engage in occasional reviews to ensure our privacy practices continue to comply with the Privacy Policy described above.  

Note that the Personal Health Information Protection Act (PHIPA) and the Personal Information Protection and Electronic Documents Act (PIPEDA) may include additional exceptions to what has been described above that are too detailed to cover in this document, given the complexity of the Act. As such, there may be rare exceptions to the commitments detailed in this privacy policy.

Additional information on your privacy rights can be obtained from:

Office of the Privacy Commissioner of Canada

www.priv.gc.ca/en/about-the-opc

1-800-282-1376
30 Victoria Street
Gatineau, Québec
K1A 1H3

Information and Privacy Commissioner of Ontario

www.ipc.on.ca/about-us

1-800-387-0073
2 Bloor Street East, Suite 1400
Toronto, Ontario
M4W 1A8